References reviewed: 10 November 2026. Confirm current requirements for the actual component and transaction.
For CNC parts intended for an EU supply chain, request substance and material information against a defined component, alloy, coating and end use. REACH information, RoHS evidence, a material certificate and a dimensional report answer different questions. A generic statement that a supplier is “EU compliant” does not establish the status of every part it makes.
The buyer’s compliance team should determine the applicable requirements; the supplier should confirm which supporting information it can provide for the specified scope. This checklist helps organize that exchange. It does not decide legal applicability or certify TDB products.
Start with the finished component and intended application
Identify the part number and revision, stock material, heat treatment, coating, plating, inserts and any other constituent items. Explain the intended application to the extent necessary and permitted. State whether the buyer is asking for information about a component, an assembly or the finished equipment.
A machined bracket for an equipment manufacturer and a complete electrical product are different review objects. Ask the responsible compliance contact to specify the requirement and the evidence expected. Avoid sending an unqualified request for “all EU certificates” that neither side can evaluate against a clear scope.
REACH and RoHS: distinguish the information streams
| Information stream | Purpose of the request | Scope to define |
|---|---|---|
| Alloy/material evidence | Support the ordered stock specification and identity. | Grade, form, condition, source lot and required document type. |
| REACH-related substance information | Support the buyer’s review of substances in the supplied article. | Applicable request, reference date, component/material identity and evidence basis. |
| RoHS-related evidence | Support an assessment for the relevant electrical/electronic application. | Product/application scope, materials/coatings, applicable restrictions and any claimed exemption. |
| Dimensional inspection | Verify agreed geometric requirements. | Drawing revision, features, method, coverage and measured results. |
| Change notification | Keep the reviewed information applicable to later deliveries. | Material, source, finish, process and component changes requiring review. |
Specify each required item in the RFQ. The quality-documentation guide explains the manufacturing-record package; this article focuses on the substance-information request and its limits.
Ask REACH questions against a dated requirement
ECHA’s guidance on Candidate List substances in articles explains that their presence can trigger obligations under defined conditions. Relevant information can come from upstream suppliers. The responsible buyer should assess the requirement and its role in the supply chain rather than treat all requests as one universal certificate.
For a practical request, identify the relevant substance-list reference or revision date, the supplied item and the question to be answered. Ask whether the response covers only the base alloy or also coatings, inserts and other included materials. Record the person and organization issuing the response and the supporting source.
Do not turn an unanswered upstream query into a declaration of absence. Mark the information as pending, explain the gap and agree a decision owner. If more evidence is required, define the targeted investigation or test scope with qualified specialists.
Review RoHS in relation to the actual application
The European Commission’s RoHS page describes restrictions associated with electrical and electronic equipment. Determine relevance to the intended product with the buyer’s compliance team. A loose CNC component should not be assigned a blanket compliance conclusion merely from its metal name.
Ask the buyer to state the applicable requirement, version and evidence basis. Where a supplier relies on an exemption, request the specific reference and its applicability to the actual application and date. Do not assume that an exemption used for another customer or product resolves this order.
A declaration should identify what it covers. If a component has multiple materials or finishes, make those boundaries visible. Resolve the scope before asking a laboratory to test an unspecified object against a broad marketing label.
Include finishing and external operations in the review
Base-stock information may not describe the final plated, coated or assembled part. List the finish specification, masking requirements and any included treatment or supplied insert. Ask which operations are performed externally and how the information from those sources will be passed through.
Use the surface-finishing guide to align the manufacturing and inspection scope. A dimensional approval after coating and a substance declaration for that coating remain separate requirements. Neither should be treated as automatically covering the other.
Use a document-request register
The following register is a buyer planning tool, not a statement that every document is mandatory or available on every TDB order. Complete it with the supplier and the responsible compliance reviewer before release.
| Register field | What to record |
|---|---|
| Requirement | Exact customer or regulatory information request and current reference. |
| Covered item | Part/revision, alloy, coating, inserts and assembly boundaries. |
| Evidence basis | Supplier declaration, upstream information or a defined test report, as agreed. |
| Reference and date | Document identifier, issue date and list/requirement version addressed. |
| Open gap | Missing material, unclear coverage or unsupported conclusion. |
| Reviewer and decision | Responsible person, due date and accepted action or release condition. |
| Change trigger | What later change requires the evidence to be reviewed again. |
Connect the register to the controlled RFQ package and purchase-order requirements. Confirm whether review is needed before material purchase, sample approval or shipment. This avoids discovering at packing that the requested evidence was never included in the quotation.
Check what a report or declaration actually establishes
Review item identity, coverage, issuer, date and the stated evidence basis. For testing, confirm the tested material or specimen, method, results and any limitations with the reviewer. A report on another alloy, an uncoated sample or a different production source may leave the ordered part unresolved.
A supplier statement and a laboratory report are different forms of evidence. Neither should be described as more comprehensive than its actual scope. Keep uncertainty and exclusions visible so the responsible buyer can make a documented decision.
Keep approved information connected to repeat deliveries
Agree how changes to material specification, source, coating, inserts or external processing are notified. Identify the effective revision or lot and what information must be refreshed. A document reviewed for the first order should not silently cover a materially changed component.
Use the revision-control guide for technical handover and the supplier-evidence review to keep scope and decision responsibilities clear. If the same EU import also raises carbon-border questions, use the separate CBAM scope checklist; substance restrictions and carbon-import obligations are distinct subjects.
Frequently asked questions
Is there one REACH or RoHS certificate for every CNC component?
Do not assume so. Define the supplied item, application, applicable request and evidence basis with the responsible reviewer.
Does a mill certificate prove every EU substance requirement?
No. It may support specified material information, but the buyer must determine whether it answers the actual substance question and covers the finished condition.
Should every shipment be laboratory-tested?
Define evidence and test needs according to the applicable requirements and risk. This checklist does not prescribe universal testing.
Can TDB confirm compliance before seeing the part specification?
A project-specific review needs the material, finish, component scope and exact request. Do not infer a blanket approval or document availability from this guide.
Define your EU documentation request
Send TDB Hanoi the controlled drawing, material and finish specifications, intended application where shareable, and the exact information or declaration requested by your compliance team.
